The country of origin of Non-Locking Doorknob Latch Sets

N362431 July 14, 2026 OT:RR:NC:N5:121 CATEGORY: Origin George Tuttle, III Tuttle Law Offices 3950 Civic Center Dr, Ste 102 San Rafael, CA 94903 RE: The country of origin of Non-Locking Doorknob Latch Sets Dear Mr. Tuttle, III: In your letter dated June 18, 2026, you requested a country of origin ruling on a Non-Locking Doorknob Latch Set on behalf of Taiwan Fu Hsing Industrial Co., Ltd. The articles under consideration are described as Non-Locking Doorknob Latch Sets. The sets are made primarily of steel and available with either doorknobs or door lever handles. Each set consists of an inside knob/lever assembly, an outside knob/lever assembly, a latch assembly, and a strike plate that are packaged together for sale and ready for installation. The inside and outside doorknob/lever assembly, the strike plate, and the latch assembly are each separate pieces and not attached to each other within the packaging. You describe a manufacturing process in which the doorknobs, levers and strike plates are manufactured in Taiwan. They will be shipped to Thailand and/or China where the doorknobs or levers will be assembled with the internal and external components of the doorknob/lever assemblies of Thailand and/or China origin. Those doorknob/lever assemblies, along with a latch assembly that is produced in Thailand and/or China, and the strike plate of Taiwan origin are then packaged in Thailand and/or China and shipped to the U.S. When determining the country of origin, the substantial transformation analysis is applicable. See, e.g., Headquarters Ruling Letter (“HQ”) H301619, dated November 6, 2018. The test for determining whether a substantial transformation will occur is whether an article emerges from a process with a new name, character, or use different from that possessed by the article prior to processing. See Texas Instruments Inc. v. United States, 681 F.2d 778 (C.C.P.A. 1982). This determination is based on the totality of the evidence. See National Hand Tool Corp. v. United States, 16 C.I.T. 308 (1992), aff’d, 989 F.2d 1201 (Fed. Cir. 1993). It is this office’s opinion that the primary function of the Non-Locking Doorknob Latch Sets is to grasp, open and close the door, a function that is provided by the doorknob/lever component. The doorknobs/levers and strike plate, which originate in Taiwan, provide the essential operational element for the doorknob/lever latch set to work. In view of these facts, the country of origin for Non-Locking Doorknob Latch Sets is Taiwan. Additionally, Section 304 of the Tariff Act of 1930, as amended (19 U.S.C. 1304), provides that unless excepted, every article of foreign origin imported into the United States shall be marked in a conspicuous place as legibly, indelibly, and permanently as the nature of the article (or its container) will permit, in such a manner as to indicate to the ultimate purchaser in the United States, the English name of the country of origin of the article. Congressional intent in enacting 19 U.S.C. 1304 was “that the ultimate purchaser should be able to know by an inspection of the marking on the imported goods the country of which the goods is the product. The evident purpose is to mark the goods so that at the time of purchase the ultimate purchaser may, by knowing where the goods were produced, be able to buy or refuse to buy them, if such marking should influence his will.” See United States v. Friedlaender & Co., 27 C.C.P.A. 297, 302 (1940). Part 134 of the U.S. Customs and Border Protection (“CBP”) Regulations (19 CFR 134) implements the country of origin marking requirements and exceptions of 19 U.S.C. 1304. Section 134.1(b), CBP Regulations (19 CFR 134.1(b)), defines “country of origin” as the country of manufacture, production, or growth of any article of foreign origin entering the United States. Further work or material added to an article in another country must effect a substantial transformation in order to render such other country the “country of origin” within the meaning of the marking laws and regulations. A substantial transformation occurs when, as a result of manufacturing process, a new and different article emerges, having a distinct name, character or use, which is different from that originally possessed by the article or material before being subjected to the manufacturing process. See United States v. Gibson-Thomsen Co., Inc., 27 C.C.P.A. 267 (C.A.D. 98) (1940). In the present case, the assembly of the separate components does not result in a substantial transformation. The doorknobs, levers, and strike plates are imported from Taiwan. The processes that occur in Thailand and/or China do not render them a new name, character or use. The end-use of the components from Taiwan is predetermined before they arrive in Thailand and/or China for further processing and assembly, as the doorknobs and levers are recognizable as a Non-locking Doorknob latch set. Pursuant to the decision in the National Hand Tool Corp. v. United States court case (16 CIT 308 (1992), aff’d, 989 F. 2d 1201 (Fed. Cir. 1993)), the Taiwan components do not substantially transform in Thailand and/or China. As a result, it is the opinion of this office that the country of origin of the Non-Locking Doorknob Latch Sets will be Taiwan for marking purposes. The holding set forth above applies only to the specific factual situation and merchandise description as identified in the ruling request. This position is clearly set forth in Title 19, Code of Federal Regulations (CFR), Section 177.9(b)(1). This section states that a ruling letter is issued on the assumption that all of the information furnished in the ruling letter, whether directly, by reference, or by implication, is accurate and complete in every material respect. In the event that the facts are modified in any way, or if the goods do not conform to these facts at time of importation, you should bring this to the attention of U.S. Customs and Border Protection (CBP) and submit a request for a new ruling in accordance with 19 CFR 177.2. Additionally, we note that the material facts described in the foregoing ruling may be subject to periodic verification by CBP. This ruling is being issued under the provisions of Part 177 of the Customs and Border Protection Regulations (19 C.F.R. 177). A copy of the ruling or the control number indicated above should be provided with the entry documents filed at the time this merchandise is imported. If you have any questions regarding the ruling, please contact National Import Specialist Jennifer Jameson at jennifer.d.jameson@cbp.dhs.gov. Sincerely, (for) James P. Forkan Director National Commodity Specialist Division